This policy applies to all USA Track & Field, Inc. (“USATF”) full time, part time, temporary, and unpaid employees (“employees”) as well as independent contractors, officers, directors, committee members, members, athletes, coaches, agents, and volunteers.

PURPOSE

USATF is committed to leadership in the sport of track & field in the United States and internationally, and because we operate in the public spotlight, we are expected to conduct our affairs consistent with this great trust that has been placed upon us. This requires that our behavior conform to the highest ethical, moral, and legal principles. In line with this commitment and USATF’s commitment to open communication, this policy aims to provide an avenue for employees, independent contractors, officers, directors, committee members, members, athletes, coaches, agents, and volunteers to raise concerns and reassurance that they will be protected from reprisal or victimization for whistleblowing. This Whistleblower Policy is intended to cover protections for you if you raise concerns regarding USATF, such as concerns regarding:

Incorrect financial reporting;

Unlawful activity; or

Activities that are not in line with USATF policy (to be used for serious and sensitive violations only), including but not limited to USATF bylaws, regulations, codes of ethics, codes of conduct, and other policies.

STATEMENT OF POLICY

No employee, independent contractor, officer, director, committee member, member, athlete, coach, agent, or volunteer of USATF shall take any harmful action with the intent to retaliate against any person, including interference with employment or livelihood, for providing to a law enforcement officer any truthful information relating to the commission or possible commission of any offense. In addition, no employee, independent contractor, officer, director, committee member, member, athlete, coach, agent, or volunteer shall take any harmful action with intent to retaliate against any employee, independent contractor, officer, director, committee member, member, athlete, coach, agent, or volunteer of USATF for the reporting any of the above-noted concerns to the appropriate USATF representative as outlined in this policy.

SAFEGUARDS

Harassment or Victimization - Harassment or victimization for reporting concerns under this policy will not be tolerated.

Confidentiality - Every effort will be made to treat the complainant’s identity with appropriate regard for confidentiality.

Anonymous Allegations - This policy encourages employees, independent contractors, officers, directors, committee members, members, athletes, coaches, agents, and volunteers to put their names to allegations because appropriate follow-up questions and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will be explored appropriately, but consideration will be given to:

The seriousness of the issue raised;

The credibility of the concern; and

The likelihood of confirming the allegation from attributable sources.

Bad Faith Allegations – Allegations made in bad faith may result in disciplinary action.

PROCEDURES

USATF seeks to have an “Open Door Policy” and encourages all employees, independent contractors, officers, directors, committee members, members, athletes, coaches, agents, and volunteers to share their questions, concerns, suggestions, or complaints regarding USATF and its operations with someone who can address them properly.

Process for Raising a Concern:

Reporting – The whistleblowing procedure is intended to be used for serious and sensitive issues. Such concerns about an officer (board member) or director (board member) may be reported directly to Counsel to the Board. Concerns regarding the Chief Executive Officer (CEO) may be reported directly to the Board Chair. Concerns about a committee member, member, athlete, coach, agent, or volunteer including those relating to financial reporting or unethical or illegal conduct, may be reported to the Ethics Committee through the General Counsel. The CEO, General Counsel, or complainant’s immediate supervisor (provided the complainant is a USATF employee) are generally in the best position to address concerns regarding an employee or independent contractor. However, if the complainant is not comfortable speaking with the party they are directed to contact, as discussed above, the complainant is encouraged to speak with either the General Counsel, Counsel to the Board, or Board Chair, whomever the complainant is most comfortable approaching.

The Audit Committee shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The General Counsel shall immediately notify the Audit Committee of any such complaint and work with the Audit Committee until the matter is resolved.

Timing – The earlier a concern is expressed, the easier it is to take action.

Evidence – Although the complainant is not expected to prove the truth of an allegation, he or she should be able to demonstrate to the person contacted that the report is being made in good faith.

Process for Handling the Report:

The action taken by USATF in response to a report of concern under this policy will depend on the nature of the concern. The appropriate designated individual(s) shall receive information on each report of concern and follow-up information on actions taken. Said person will acknowledge receipt of the reported violation or suspected violation by writing a letter (or e-mail) to the complainant within ten (10) business days of receipt of the complaint.

Initial Inquiries – Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take. Some concerns may be resolved without the need for investigation.

Further Information – The amount of contact between the complainant and the person or persons investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from or provided to the person reporting the concern.

Information­ – Subject to legal constraints, the complainant will receive information about the outcome of any investigations.

For additional information, contact the General Counsel or the Ethics Committee.

USATF reserves the right to modify or amend this policy at any time as it maydeem necessary.